Show download pdf controls
  • Transfer pricing legislation update

    Transfer pricing legislation has been updated to refer to the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017External Link as the relevant guidance material. It will be applied retrospectively for income years starting on or after 1 July 2017.

    The 2017 OECD transfer pricing guidelines includes revisions made as a result of the Aligning Transfer Pricing with Value Creation, Actions 8-10 Final Reports of the OECD, amongst other things. This guidance material is relevant for determining the arm’s length conditions in respect of multinational enterprises’ cross-border dealings.

    The 2017 OECD transfer pricing guidelines are commonly referred to by taxpayers and the retrospective application ensures greater certainty for taxpayers and advisors by commencing shortly after the OECD’s Committee on Fiscal Affairs adopted the 2017 transfer pricing guidelines.

    This update forms part of Australia’s ongoing commitment to strengthen our transfer pricing provisions in line with international best practice. It will help ensure that multinational enterprises are paying their fair share of tax in Australia.

    We will be updating our guidance material that references the 2010 transfer pricing guidelines and the Actions 8-10 Report, and will notify you of updates via our Business Bulletins newsletter.

    See also:

    Last modified: 03 Aug 2020QC 63321